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Comes now petitioner, through herein counsel unto this Honorable Court
respectfully avers that:

1. He is a Filipino citizen, of legal age, with capacity to sue and be sued,

married to respondent of 416 Burgos St., Brgy. Sto. Nio, Tanauan, Leyte,
Philippines. He could also be served with summonses and other processes
by the Honorable Court at his residence.

2. Respondent is likewise a Filipino citizen, of legal age, with capacity to sue

and be sued, married from herein petitioner with the same address of 416
Burgos St., Brgy. Sto. Nio, Tanauan, Leyte, Philippines, where she could
be served with summonses and other processes by the Honorable Court at
her residence.

3. Parties are capacitated to sue and be sued;

4. Petitioner and Respondent civil wedding1 was solemnized on December

09, 2000 at the Municipal Trial Court, Tanauan, Leyte.

5. Their union bore one child, who was born on January 20, 2002, who died
5 months later.

6. Petitioner was born and brought up by his biological parents. They lived in
Brgy. Mohon, Tanauan, Leyte, Philippines.

7. Respondent likewise was born and brought up by her biological parents.

They lived in Brgy. Buntay, Tanauan, Leyte, Philippines.

8. Petitioner was 26 years old and respondent was 36 years of age.

9. Petitioner testifies that she respondents incapacity existed at the time

their marriage was celebrated and still subsists up to the present.

Please refer to the Certificate of Marriage issued by NSO hereunto attached as ANNEX-A.
10. As manifestations of respondents alleged psychological incapacity,
petitioner claimed that respondent persistently lied about herself, the
people around her, her occupation, income, educational attainment and
other events or things.

11. Respondent concealed the fact that she previously gave birth to an
illegitimate son, and instead introduced the boy to petitioner as the
adopted child of her family. She only confessed the truth about the boys
parentage when petitioner learned about it from other sources after their

12. Respondent fabricated a story that her brother-in-law, Glenn Quagmire,

attempted to rape and kill her when in fact, no such incident occurred..

13. Respondent misrepresented herself as a psychiatrist to her obstetrician,

Dr. Cleveland Brown, and told some of her friends that she graduated with
a degree in psychology, when she was neither.

14. Respondent claimed to be a singer or a free-lance voice talent affiliated

with Fox Recording Company; yet, not a single member of her family ever
witnessed her alleged singing activities with the group.

15. Respondent invented friends named Jillian Russell and Tricia Taka, and
under those names, sent lengthy letters to Petitioner claiming to be from
Fox and touting her as the number one money maker in the commercial
industry worth P2 million. Petitioner later found out that Respondent
herself was the one who wrote and sent the letters to him when she
admitted the truth in one of their quarrels. He likewise realized that Jillian
Russell and Tricia Taka were only figments of her imagination when he
discovered they were not known in or connected with Fox.

16. Respondent represented herself as a person of greater means, thus, she

altered her payslip to make it appear that she earned a higher income.

17. Respondent bought a sala set from a public market but told Petitioner that
she acquired it from a famous furniture dealer.

18. Respondent spent lavishly on unnecessary items and ended up borrowing

money from other people on false pretexts.

19. Respondent exhibited insecurities and jealousies over Petitioner to the

extent of calling up his officemates to monitor his whereabouts.

20. Petitioner could no longer take her unusual behavior. He separated from
her in August 2003.

21. He tried to attempt a reconciliation but since her behavior did not change,
he finally left her for good in November 2004.

22. In support of his petition, Petitioner presented Dr. Joe Swanson, a

psychiatrist, and Dr. Elmer Hartman, a clinical psychologist, who stated,
based on the tests they conducted, that Petitioner was essentially a
normal, introspective, shy and conservative type of person. On the other
hand, they observed that Respondents persistent and constant lying to
Petitioner was abnormal or pathological. It undermined the basic
relationship that should be based on love, trust and respect. They further
asserted that Respondents extreme jealousy was also pathological. It
reached the point of paranoia since there was no actual basis for her to
suspect that Petitioner was having an affair with another woman. They
concluded based on the foregoing that respondent was psychologically
incapacitated to perform her essential marital obligations.


WHEREFORE, PREMISES CONSIDERED, petitioner respectfully prays

that the Honorable Court gives due course to this petition and declares her
marriage to herein respondent null and void by reason of the psychological
incapacity of the latter to fulfill her marital obligations and ordering the
respective offices of the Local Civil Registrar keeping the record of such marriage
to make the necessary corrections thereon.

Petitoner also prays for all other just and equitable reliefs the Honorable
Court may deem proper under the circumstances. Tacloban City for Tanauan,
Leyte, October 31, 2017.


Counsel for the Petitioner
ECC Law & Notarial Office
2/F LY Building, Brgy. 77
Fatima Village, Marasbaras, Tacloban City
Attys. Roll No. 82456 / May 10, 2010
PTR No. 8000244/1-4-16 Tanauan, Leyte
IBP O.R. NO. 9876543/01-04-16 Tacloban City
MCLE COMPLIANCE NO.: V-5556878/11-24-2017
Phone Numbers: (053) 526-9206/09267274521
Email: eugenecayobit@gmail.com

I, PETER GRIFFIN, of legal age, and a resident of 416 Burgos St., Brgy.
Sto. Nio, Tanauan, Leyte, after having been duly sworn in accordance with law,
depose and state that:

1. I am the petitioner in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or any other tribunal or

5. To the best of my knowledge and belief, no such action or proceeding is

pending in the Supreme Court, the Court of Appeals, or any other tribunal
or agency;

6. If I should thereafter learn that a similar action or proceeding has been

filed or is pending before the Supreme Court, the Court of Appeals, or any
other tribunal or agency, I undertake to report that fact within five (5) days
thereon to this Honorable Court

IN WITNESS HEREOF, I have hereunto affixed my signature this day,

____________, in Tacloban City, Philippines.


Subscribed and sworn to before me this day, ____________, affiant

showing to me her DRIVER'S LICENSE ID with ID NUMBER: HO9-14-001087.

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